Posted on 10/10/2008 1:29:21 AM PDT by Lancey Howard
Attached is Philip J. Berg's Opposition to Defendants, the DNC and Obama's Motion for Protective Order Staying Discovery pending Decision on their Motion to Dismiss. If the Protective Order were granted, discovery could not occur until the standing issue has been resolved and only if it is in favor of the plaintiff.
Following is an excerpt from the response:
PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANTS BARACK H. OBAMA AND THE DEMOCRATIC NATIONAL COMMITTEE’S MOTION FOR A PROTECTIVE ORDER STAYING DISCOVERY PENDING DECISION ON DISPOSITVE MOTION Plaintiff, Philip J. Berg, Esquire [hereinafter “Plaintiff”] files the within Response in Opposition to Defendants, Barack H. Obama [hereinafter “Obama”] and the Democratic National Committee [hereinafter “DNC’] Motion for Protective Order Staying Discovery Pending Decision on Defendants Dispositive Motion on the following grounds: 1. Defendants’ pending Motion to Dismiss does not entitle them to a Protective Order under Federal Rule of Civil Procedure 26(c) [hereinafter F.R.C.P. 26(c]; 2. Defendants have failed to show “good cause” and are therefore not entitled to a protective order under F.R.C.P. 26(c); 3. Defendants have not pointed to any legitimate privacy concerns. Defendants have failed to point out any substantiated specific examples demonstrating that disclosure will cause a defined and serious injury;
4. Plaintiff does not seek access to the requested information for any improper purpose; 5. Defendants have not shown any risk that particularly serious embarrassment will result from the requested documents; 6. The requested information is extremely important for public safety; and “Good Cause” requires a particular need for the protection sought; 7. The sharing of information will promote fairness and efficiency so as not to delay this action; 8. Barack Obama, as U.S. Senator of Illinois and the Democratic Nominee for President of the United States, is a public person, and his citizenship status is a matter of significant public concern and is subject to legitimate public scrutiny. The Democratic National Committee is a public entity and is also subject to public scrutiny; and 9. The public interest in access to the requested information under the Freedom of Information Act 5 U.S.C. § 552 is a strong factor in favor of not granting a protective order which would prevent disclosure of such information.
Probably "All of the above "
That is a certificate of live birth ( COLB) posted on BHO’s site. It has been challenged as being a fake. What Berg is suing for is called the “vault certificate”. It shows the name of the hospital where he was born. The COLB is basically a summary issued when requesting a birth certificate.
That was long ago proven to be a fake document.
Probably "All of the above "
Don’t know why my last posted three times, only submitted it once :-)
here’s my question...WHO exactly vets these candidates? Is it the Secret Service? DOJ? FBI?
Part of the mythological archetype of the hero is that his origin is obscure. Obama went to an Ivy League college; he knows that. There you don’t achieve heroic stature fighting in wars or on the athletic field, you do it the good old fashioned Joseph Campbell way: symbollically.
The media.
“AMEN! AMEN! Lord, please let this blow up in the Obamma camp’s faces wholesale at the worst possible time.”
The risks of this blowing up and becoming a huge media event are:
A) BHO was actually born in Hawaii
B) BHO has “bribed” Hawaii officials to create a fake document, end result is “A” above.
C) Legitimate or “Legitimate” document is produced at the height of media fury and this train is derailed with huge media exposure in favor of BHO, casting aspersions of doubt on other claims of impropriety against him.
Location,location,location!
Thanx
The answer, I believe, is NO ONE.
While the Constitution states qualifications for the Office of the President, it doesn't say who has the standing to check and enforce them.
Barack Obama needs to be asked why he continues to associate and break bread with people who detest the America that we love. He needs to be asked why those people, even ones he may not know, even ones like Hugo Chavez or Mahmoud Ahmadinejad, are supporting him and rooting for him to be successful on the fourth of November. On page 100 of his bestselling memoir, Dreams from My Father: A Story of Race and Inheritance, Barack Obama wrote the following:
To avoid being mistaken for a sellout, I chose my friends carefully. The more politically active black students. The foreign students. The Chicanos. The Marxist Professors and the structural feminists and punk-rock performance poets. We smoked cigarettes and wore leather jackets. At night, in the dorms, we discussed neocolonialism, Franz Fanon, Eurocentrism, and patriarchy. When we ground out our cigarettes in the hallway carpet or set our stereos so loud that the walls began to shake,we were resisting bourgeois society's stifling constraints. We weren't indifferent or careless or insecure. We were alienated.
Go and get the details at:
http://www.americasright.com/
Recommended reading!!!
“Any facts to the contrary are racist!”
So i’m a racist!
I fear this will drag in the courts until it is too late.
“Obama went to an Ivy League college”
That’s an admission of getting an inferior education as far as i’m concerned.
“The COLB is basically a summary issued when requesting a birth certificate.”
Authentic ones also have the state seal which this phony doesn’t.
"He chose is friends carefully" is a damning statement in light of what he has said about Ayers and others.
“Lord, please let this blow up in the Obamma camp’s faces wholesale at the worst possible time.”
I would hope this would “blow up” in the Obama Camp’s faces in an extraordinary manner at the BEST possible time to be most effective in ruining the “Communist Gangbanger’s” chances at achieving his goal.
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